Subject: Re: Response to John Schwartz' Questions
John Schwartz (schwartz@usa.net)
Date: Fri, 03 Jul 1998 14:42:46 -0600
Message-Id: <3.0.3.32.19980703144246.0075ff34@postoffice.att.net> Date: Fri, 03 Jul 1998 14:42:46 -0600 To: roundtable@cni.org From: John Schwartz <schwartz@usa.net> Subject: Re: Response to John Schwartz' Questions In-Reply-To: <359BD8EE.AEB@apt.org>
Maureen Lewis <mlewis@apt.org> posted the following reply written by Don
Vial, APT's policy chair. I exerpt:
>
> "Your selective questioning of APT's recommendations to remove
> barriers to advanced telecommunications infrastructure, such as ADSL,
> has us somewhat puzzeled as our recommendations to remove those
> barriers appear to be read by you in splended isolation of our
> recommendations (p.28-41 of filing) to promote pro-actively
> infrastructure investments for advanced capablilities, partilcular
> to bring marginalized communities into the orbit of the digital age.
Please keep in mind that my questions were in response to Maureen
Lewis's posting of a summary of the APT's position. I do not pretend
to have a full knowledge of APT's filings. One reason I value the
roundtable list is that I often gain insights without having to plow
through hundreds of pages of pleadings. I imagine that such also may
have been part of Maureen's motive in making the posting.
My questions were interspersed with portions of Maureen's message.
Maureen's exposition contained elements that did not -- and do not --
make sense to me.
Don's reply was a good general account of a quandary in
telecommunications regulation. If one opens telephone/telecom markets
to competition, competitors will first try to "cream skim" the most
attractive submarkets -- generally businesses customers in dense areas.
CLECs are indeed unlikely to address the needs of low income
communities. Yet ILECs without competition are horrendously inefficient
and unresponsive, so it is difficult to argue that they should remain
insulated from competitors.
Apparently, the APT choice is to incent incumbents. I have doubts about
this approach, but, even if one endourses it, one has to maintain close
connections between the incentives offered and the results anticipated.
(Monopoly incentives without results is a pretty terrible combination.)
In his reply Don answered my question about colocation. But he did not
address the other two questions I posed. While he may believe that
these items have been taken out of context, they are APT's positions
unless Maureen erred---and they are issues APT needs to confront. I
repeat the unanswered questions below (for the fourth time).
Taken from Maureen's posting:
> >
> > Suggestions about limiting Sec. 251 unbundling requirements relate
> > solely to widely available elements like switches and transport and
> > exclude the loop. APT Pet. at 20.
Taken from my reply:
>
> Is it APT's view that such unbundling inhibits investment? If so, the
> logic is not immediately obvious to me. If not, what is the rationale
> for imposing such limits?
My further observation: How does the limiting of unbundling assist low
income communities?
Maureen:
> >
> > --RBOC entry into long distance is not raised in these filings. The
> > petition does, however, recognize that Sec. 10 of Telecom Act requires
> > full implementation of Secs. 271 and 251 before FCC can forbear
> > enforcement of 251(c).
My reply:
>
> This appears circular to me. If Section 251 is implemented initially,
> and then the FCC forbears from enforcing 251(c), and then ILECs cease
> to comply with 251(c), the process of opening ILEC networks will be
> frustrated.
My further questions: do you agree that there is the potential to
frustrate the opening of ILEC networks in this manner? If not, why not?
If yes, what is the corresponding benefit to low income communities (or
anyone else)?
In conclusion, I do not like becoming strident over roundtable, as I
recently did. But neither do I like it when it appears that APT is willing
to promote its positions, but not answer questions about them. I hope I
will not have to make three more postings before I get a responsive reply
to the above.
J.
_____________________________________________________________________________
John B. Schwartz
P.O. Box 6060 Telephone 303-442-2707
Boulder, CO 80306 FAX 303-442-6472
schwartz@usa.net
_____________________________________________________________________________
This archive was generated by hypermail 2a16 : Tue Mar 23 1999 - 03:33:38 EST